Did I get your attention with that one?
In our world without DCAA, contractors are getting desperate to meet the requirement for an adequate accounting system, desperate enough to try and pass off an adequacy determination for an INCURRED COST PROPOSAL as proof of an adequate accounting system when bidding on government contracts.
What makes it worse is they got away with it until the federal court called such a reliance “irrational”. Yes, the CO accepted the assertion that a adequate incurred cost proposal is the same as an adequate accounting system.
In the United States Court of Federal Claims, Citizant vs. The United States, No. 18-856C